Aldo Engels
Counsel - Attorney at Law
Aldo Engels, attorney at law, is a member of the Loyens & Loeff Direct Tax Practice Group and heads the Transfer Pricing Team in Belgium. He is a counsel in our Brussels office.
Aldo advises on corporate and international tax matters, with a strong focus on transfer pricing. His counsel in transfer pricing includes strategic advice, documentation & pricing, negotiations with tax authorities, dispute resolution and litigation. He advises on business model design & conversion, restructurings & procurement models, permanent establishment issues and transactions involving intangibles. He has a strong passion for intra-group financing, including analysing and modelling optimal financing structures, loan pricing, cash pool models, and real estate financing.
Beyond transfer pricing, Aldo has extensive experience in investment structuring and withholding tax matters, tax treaty issues (including PE and MLI impact), Pillar II, restructuring & insolvency related tax matters as well as financial institutions & exchange of information mechanisms (FATCA & CRS). Finally, he regularly advises on the tax aspects of financing transactions, such as structured finance, syndicated loans, factoring/securitization, and capital markets transactions. Aldo is also recognised in his field of expertise by ITR and Leaders League.
Work highlights
Contributions
Memberships
Brussels Bar, 2012
Qualifications
Advanced Transfer Pricing course within the LL.M. (Adv.) Program in International Tax Law, ITC Leiden (The Netherlands), 2013
Master’s degree in Tax Law, Université libre de Bruxelles (Belgium), 2012
Master’s degree in Law, Katholieke Universiteit Leuven (Belgium), 2011
Publications
A. ENGELS and W. STRIJCKERS, “TP-richtlijnen voor financiële transacties : si vis pacem, para bellum”, in Fiscoloog Internationaal (July 2020).
A. ENGELS and Y. VAN BRUSSEL, “Het MLI en de Belgische belastingverdragen: iacta alea est”, in Fiscoloog Internationaal (31 August 2019)
N. REYPENS, A. ENGELS and W. STRIJCKERS, “Belgium” in Lexology Transfer Pricing 2020 (July 2019)
A. ENGELS, “Transfer pricing aspecten van financiële transacties : OESO-discussietekst” in Fiscoloog Internationaal (31 July 2018)
Aldo Engels
Counsel - Attorney at Law
aldo.engels@loyensloeff.com
Brussels
Dutch, English, French
<p>Aldo Engels, attorney at law, is a member of the Loyens & Loeff Direct Tax Practice Group and heads the Transfer Pricing Team in Belgium. He is a counsel in our Brussels office. <br></p>
Aldo advises on corporate and international tax matters, with a strong focus on transfer pricing. His counsel in transfer pricing includes strategic advice, documentation & pricing, negotiations with tax authorities, dispute resolution and litigation. He advises on business model design & conversion, restructurings & procurement models, permanent establishment issues and transactions involving intangibles. He has a strong passion for intra-group financing, including analysing and modelling optimal financing structures, loan pricing, cash pool models, and real estate financing.
Beyond transfer pricing, Aldo has extensive experience in investment structuring and withholding tax matters, tax treaty issues (including PE and MLI impact), Pillar II, restructuring & insolvency related tax matters as well as financial institutions & exchange of information mechanisms (FATCA & CRS). Finally, he regularly advises on the tax aspects of financing transactions, such as structured finance, syndicated loans, factoring/securitization, and capital markets transactions. Aldo is also recognised in his field of expertise by ITR and Leaders League.